EU legislation provides the implementation of most building energy performance measures at a subnational level. This obligation is causing a lot of completely new dilemmas that are challenging for local governments (LGs), requiring a radical re-evaluation of the prioritization of LGs’ traditional tasks and the ranking of new responsibilities. The attitude of local population and businesses towards the solutions to dilemmas, which are set by LGs decisions, vary widely. Separate groups actively lobby for their mutually contradictory interests, questioning decisions and fighting against them during the decision-drafting and -making process, significantly hindering the work of LGs and prolonging decision-making. The authors’ suggested solution to the problem is to make municipal decisions based on verifiable data and facts, thus preventing the manifestations of populism and demagogy, and reducing the possibilities for interest group advocacy. To obtain objective information for balanced decision-making about the benefits and costs of heating system retrofitting projects without carrying out the labor-intensive, time-consuming, and costly design of various options, an express methodology and an easy-to-use tool for project feasibility studies have been developed. The methodology utilizes a limited number of open indicators to streamline the evaluation process, and does not require specific knowledge in thermal physics, economics, or construction.

EU legislation provides for extensive involvement of local governments (LGs) in the implementation of the "energy first" principle concerning buildings’ stock. LGs have a dual role. In the role of national government agents LGs co-financing is necessary for implementation of global goals. In the role of autonomous decision makers LGs are balancing various interests on behalf of local community. The aim of the research is to assess the characteristics of those interest groups that are short- and medium-term beneficiaries or losers from the EU recommendations and the risks arising from the choice of alternatives. Interests of groups are evaluated by the approximation of the Rational Choice Theory, considering diversity of competences division among national and subnational authorities. Evaluated alternatives: 1) security in the event of war versus voluntary initiatives for energy efficiency; 2) prolonging regeneration of woods’ biomass versus electrification of heating; 3) supporting entrepreneurship versus reduction of energy poverty; 4) individual or energy community solutions versus uniform treatment of all DHSs customers; 5) postponing versus acceleration of the electrification of transport; 6) re-municipalisation versus outsourcing buildings stock and its infrastructure renovation. Losers of energy performance policy should be compensated in the short and middle term, because possible future gains may be insufficient to maintain stability.